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. … [A]ssuming that all the property transmitted to the various trusts comes from the testator, Mr. ...

If the request for a refund from the Romanian tax authorities is denied and the assessment is upheld, Xco may follow the procedures outlined in Article 25 [re MAP] … and make a written request to the CRA's Legislative Policy Directorate for a foreign tax credit. ...

Accordingly … only the taxable capital of the CCPC (Xco) should be considered for purposes of the proposed amendments to subsection 125(5.1) since the facts submitted indicate that the associated corporation (Yco) does not carry on business through a permanent establishment in Canada within the meaning of subsection 400(2) of the ITR. ...

CRA assumed that the wife will designate Immovable2 as her principal residence for the years 1995 to 2006 inclusive (as well as 1992, 1993, and 1994) and that, as a result, the husband must designate the same property for the years 1995 to 2006 – in which case, Immovable1 would be treated as a capital property subject to the change-in-use rules. ...

. … [I]t is clear from the wording of subparagraph 256(1.2)(f)(ii) that Parliament intended this provision to apply where a person is named as a beneficiary in the trust indenture, and the person's share of the trust's income or accumulated capital is conditional on the exercise or non-exercise of discretion in that regard. ...

. … In the situation described above, the effect of subsection 87(2.1) would be that the Subco2 Loss incurred in its taxation year that ended on December 31, 2003, would become a Amalco2 Loss for the same taxation year. ...

. … Rather, the plan is the agreement between the employer and its employees or a group or association of employees that provides compensation to an employee for loss of employment due to illness or accident. ...

However, in the year of resignation, i.e. 2006, since the salary for the last two pay periods was withheld to recover part of the prepaid salary, the amount of salary received by the employee- net of the deductions made by the employer – was to be included in the employee's income for 2006 In addition, any cheques written by the employee in 2006 for prepaid salary reimbursements would reduce his employment income for 2006 and, if repaid in 2007, would reduce the employee's 2006 employment income, so that the employer would be required to file an amended T4 slip for that taxation year. ...

Thus, in such a situation, the trust would no longer be a "testamentary trust" …. ...

On the other hand, if one unit has all the bedrooms and the other unit consists primarily of the kitchen and bathrooms and they are truly used as one unit, the CRA may be more likely to conclude that there is a single unit for purposes of the definition of "principal residence" …. ...